Patna High Court

Ranjit MandalversusThe State of Bihar

Decided: 12 March 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The Court granted anticipatory bail to the petitioner subject to bond, sureties and conditions under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023.

Summary

The petitioner, Ranjit Mandal, sought anticipatory bail fearing arrest in a case where 810 litres of liquor were seized and offences under Sections 274, 275, 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Section 30(a) of the Bihar Prohibition and Excise Act were alleged. The prosecution’s case relied on a confessional statement of a co‑accused, while the petitioner’s counsel argued that he was falsely implicated, had no knowledge of the recovery, and that the seizure occurred in a public open place, rendering no prima facie case. The counsel also highlighted non‑compliance with Section 103 of the Bharatiya Nagarika Suraksha Sanhita, 2023. The State opposed the bail. The Court, after considering the submissions, granted anticipatory bail on the condition that the petitioner surrenders within six weeks, furnishes a bail bond of Rs.15,000 with two sureties of equal amount, and complies with conditions under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita.

Issues considered

Whether anticipatory bail should be granted to the petitioner under the circumstances.
Whether there is a prima facie case against the petitioner based on the co‑accused’s confessional statement.
Whether the requirements of Section 103 of the Bharatiya Nagarika Suraksha Sanhita, 2023 have been complied with.
Whether conditions under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023 are applicable.

Legislation cited

Bharatiya Nagarika Suraksha Sanhita, 2023 — s. 103, 482(2)
Bharatiya Nyaya Sanhita, 2023 — s. 274, 275, 3(5)

Subjects

anticipatory bail
liquor seizure
false implication
confessional statement
Section 103
Section 482
criminal procedure
Bihar

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.15497 of 2026
                   Arising Out of PS. Case No.-180 Year-2025 Thana- MADHWAPUR District- Madhubani
                 ======================================================
                 Ranjit Mandal Son of Bahur Mandal Resident of Village - Balwa, Ward No.-
                 03, P.S.- Madhwapur, District - Madhubani
                                                                           ... ... Petitioner/s
                                                    Versus
                 The State of Bihar
                                                                    ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Ravindra Kumar Singh, Advocate
                 For the Opposite Party/s :      Mrs. Renu Kumari, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   12-03-2026                   Heard learned counsel for the petitioner and learned

                   APP for the State.

                               2. The petitioner apprehends his arrest in connection

                   with Madhwapur P.S. Case No. 180 of 2025 instituted for the

                   offences punishable under Sections 274, 275, 3(5) of the

                   Bharatiya Nyaya Sanhita, 2023 and 30(a) of the Bihar

                   Prohibition and Excise Act.

                               3. The prosecution case, in short, is that total 810 litres

                   of liquor was recovered from plastic sack.

                               4. Learned counsel for the petitioner submitted that the

                   petitioner has falsely been implicated in the present case. The

                   name of the petitioner transpired in this case on the basis of

                   confessional statement of the apprehended co-accused. Learned

                   counsel further submitted that petitioner has no knowledge and
           Patna High Court CR. MISC. No.15497 of 2026(2) dt.12-03-2026
                                                       2/2




                     concern with the alleged recovery. Learned counsel further

                     submitted that the alleged recovery has been made from an open

                     place which is accessible to public at large. Learned counsel ,

                     therefore, submitted that prima-facie, no case is made out

                     against the petitioner. The petitioner has one criminal

                     antecedent. There is no compliance of Section 103 of the

                     Bharatiya Nagarika Suraksha Sanhita, 2023.

                                5. Learned APP for the State has vehemently opposed

                     the prayer for grant of bail to the petitioner.

                                  6. Considering the aforesaid facts and circumstances

                     of the case, let the petitioner, above named, in the event of

                     arrest/surrender before the lower court within a period of six

                     weeks from today, be released on anticipatory bail on furnishing

                     bail bonds of Rs. 15,000/- ( Rupees Fifteen Thousand) with two

                     sureties of the like amount each to the satisfaction of Court

                     below/concerned Court in connection with Madhwapur P.S.

                     Case No. 180 of 2025, subject to the conditions as laid down

                     under Section 482(2) of the Bharatiya Nagarika Suraksha

                     Sanhita, 2023.



                                           (Rudra Prakash Mishra, J)
Alok Verma/-

U      T

Continue reading with your account

Checking your session…